Aug
27

CRE Comments on EPA’s Atrazine Registration Review

CRE submitted comments to EPA on the Agency’s FIFRA registration review for atrazine.  EPA is just beginning the registration review process, so CRE will probably file subsequent comments.  CRE’s comments made the following among other points.

First, EPA’s atrazine registration review should document its compliance with EPA’s Information Quality Act (“IQA”) Guidelines. For example, EPA should document that the atrazine review and any atrazine consultations under the Endangered Species Act comply with the IQA Guidelines as expounded by the National Research Council’s report Assessing Risks to Endangered and Threatened Species from Pesticides. EPA should also document that the atrazine review and any atrazine consultations under the ESA comply with EPA’s Council for Regulatory Environmental Models (“CREM”) Guidance.

Aug
23

CRE Comments on EDSP Tier 2 ICR

CRE filed comments on EPA’s Information Collection Request for EPA’s Tier 2 EDSP tests. CRE commented that  EPA should not submit, and OMB/OIRA should not approve, this ICR because EPA has not demonstrated that the EDSP Tier 2 tests meet Information Quality Act (“IQA”) Guidelines and Paperwork Reduction Act (“PRA”) requirements. For example, EPA has not demonstrated that the EDSP Tier 2 tests are reliable, reproducible, and useful. EPA has also not demonstrated that the EDSP Tier 2 tests are the least burdensome necessary, and that they are necessary for the proper performance of EPA’s functions.

Click here to read CRE’s comments.